Rubik’s Pubes vs. League Commissioner – 4 F.J. 98 (June 27, 2012) – Fantasy Baseball Trade Rules Dispute

SUPREME COURT OF FANTASY JUDGMENT

Rubik’s Pubes vs. League Commissioner

ON PETITION FOR WRIT OF CERTIORARI FROM THE 1980’s FANTASY BASEBALL LEAGUE 

Decided June 27, 2012

Cite as 4 F.J. 98 (June 2012)

Factual Background

A rotisserie fantasy baseball league called the 1980’s Fantasy Baseball League (hereinafter referred to as “roto league” or “1980’s”) is a 14-team AL/NL mixed keeper league and has been in existence since 2004.  The league utilizes an auction-style draft and transaction platform on CBSSports.com.  Teams are permitted to maintain up to five (5) players during each off-season with individual players allowed to be kept for a maximum of three (5) consecutive years under contract.  Each team is also permitted to keep three minor league players which are in addition to the five players kept.  This roto league also has a $260.00 draft salary cap.   

As with many rotisserie leagues, the 1980’s uses the standard 5×5 scoring categories to determine the standings and prize money.  For offensive players, the five categories are: (1) batting average; (2) homeruns; (3) runs batted in; (4) runs scored; and (5) stolen bases.  For pitchers, the five categories are: (1) wins; (2) earned run average; (3) WHIP (walks+hits/innings pitched); (4) strikeouts; and (5) saves.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the roto league.

The league is governed by a written constitution which includes rules and guidelines regarding the making of trades between teams.  The following represents the provision with respect to trades in pertinent part:

Section VI.  Trades

A.        Trades are permitted between any two teams and are subject to approval by the league commissioner.

B.        There is no limit to the number of trades that can be made by each team.

C.        Trades may only be made up until the deadline of August 31, 2012.  Trades may not be made again until after the conclusion of the 2012 World Series.

D.        Trades are permitted in the off-season and are subject to the same approval process as delineated above.

*          *          *          *          *

G.        The commissioner shall have the authority to reject trades made through collusion or that are otherwise completely lopsided to the detriment of the league.

H.        Any trade made by the league commissioner shall be subject to approval by the co-commissioner.

 *          *          *          *          *

L.         There is no recourse for appealing the commissioner or co-commissioner’s decision regarding the approval or rejection of a trade.  The league members hereby consent to the commissioner and co-commissioner’s authority and discretion to make such final decisions.  

On June 26, 2012, a trade was made between the teams of Biff Tannen Loves Manure (“Biff Tannen”) and Space Shuttle Challenger (“Challenger”).   Biff Tannen traded Tim Lincecum (SP-SF) and Chase Utley (2B-PHI) to Challenger in exchange for Trevor Bauer (SP-ARZ), Bobby Parnell (RP-NYM), and Ryan Lavarnway (C-BOS).  The commissioner subsequently approved the trade and an automated email was generated from CBS announcing the trade to the rest of the league.

Procedural History

After learning of the trade, the team known as Rubik’s Pubes contacted the commissioner challenging the approval of the trade.  Rubik’s Pubes argued that the trade was unfair and should have been rejected.  The commissioner rejected Rubik’s Pubes appeal and reminded him that the rules state the commissioner’s decision regarding trades is final.

Despite what the commissioner said and what is written in the league constitution, Rubik’s Pubes submitted this case to the Court seeking a reversal of the commissioner’s decision to approve this trade.  The commissioner has stated that Rubik’s Pubes should not be able to submit this case for review because the league’s rules clearly state that there is no recourse for challenging his decisions on trades.

Issues Presented

(1)        Does Rubik’s Pubes have standing to bring this appeal to the Court?

(2)        If Rubik’s Pubes does have standing, should the trade between Biff Tannen and Challenger be upheld?

Decision

Fantasy sports league commissioners are empowered with the tasks of creating the league’s rules, settings, and guidelines.  Bryan LaHair Club For Men vs. League Commissioner, 4 F.J. 26, 28 (April 2012).  The Court strongly advocates for commissioners to codify these rules in a written constitutions for a myriad of reasons.  John Doe vs. Fantasy Football League Commissioner, 2 F.J. 21, 22 (October 2010). 

One of the primary reasons to have a constitution is so that all league members are aware of the rules and guidelines in place that govern the administration and function of the fantasy league.  When a league commissioner writes out the rules and distributes them to the league, it shifts the burden onto the league members to read, understand, and adhere to the rules that are delineated.  Shawn Kemp is My Daddy vs. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).   If a league member has an issue, question or challenge to one of the rules in the constitution, they are welcome to raise this with the commissioner before signing it or agreeing to its codification.   Machine vs. Fantasy Football League Commissioner, 2 F.J. 1, 2 (September 2010).

Here, the roto league does have a constitution which grants the commissioner the power and authority to rule on pending trades.  The criteria for rejecting trades include collusive conduct or lopsided deals that are detrimental to the league as a whole.  There does not appear to be any allegations of collusion, so the commissioner’s basis for rejecting the trade was based on his evaluation of the trade as being lopsided and inequitable. 

The constitution also provides the commissioner with the final authority to approve or reject trades that he is not a party to.  Subsection L under Section VI. of the league constitution codifies the commissioner’s powers as follows:

L.         There is no recourse for appealing the commissioner or co-commissioner’s decision regarding the approval or rejection of a trade.  The league members hereby consent to the commissioner and co-commissioner’s authority and discretion to make such final decisions.  

There is no indication that the language of this provision was ever challenged or questioned by any members of the league at the time the rules were set forth and distributed.  By participating in the league with an existing written constitution, the league members are bound to the rules set forth. 

Clearly there are circumstances where the commissioner’s power and authority morphs into an abuse of discretion which must be curtailed.  See Cincinnati Bungles vs. O&A’s Two Point Conversion, 3 F.J. 88, 90 (July 2011).  However, the ability to approve or reject trades does not rise to this level, especially when there are checks and balances on trades the commissioner makes for his own team.  One of the primary reasons league commissioners retain the authority to approve or reject trades is because league votes tend to inhibit people’s ability to make deals.  Relying on all other league members to objectively vote on a trade doesn’t always lead to the fairest decisions. 

There is nothing in the rules that warrants a check or balance on the commissioner’s ability to decide whether a trade should be approved or not.  That being said, we must determine whether Rubik’s Pubes can even bring this appeal in the first place.  The legal doctrine of standing is where a plaintiff must have a personal stake or interest in a dispute that has been invaded by the defendant in order to obtain judicial relief.  Here, Rubik’s Pubes is a member of the roto league and does in fact have a financial interest in the outcome of the league.  Even though he was not a party to the underlying trade, his team and the results of the league could potentially be affected by the outcome of the trade.  Based on this analysis, Rubik’s Pubes does have legal standing.

However, in terms of whether he has standing in the context of his fantasy baseball league, the Court comes to a different conclusion.  The rules do clearly state that “there is no recourse for appealing the commissioner or co-commissioner’s decision regarding the approval or rejection of a trade.”  When the rules of a league are delineated in a written document, they should be adhered to unconditionally unless there are extenuating circumstances that would justify a deviation from the document.  Justin Verlander’s School for People Who Don’t Pitch Good vs. Angel Pagan Worshippers, 3 F.J. 105, 106 (August 2011). 

There is no discernible reason to make an exception here for Rubik’s Pubes to be able to challenge the commissioner’s decision on a trade.  The commissioner has not done anything outside the bounds of his authority.  Other league members are certainly entitled to disagree with the decisions he makes.  However, they have tacitly agreed to the rules of the league as set forth in the constitution.  Included in those rules is the fact that there is no ability to challenge or dispute decisions on trades.

Based on the foregoing, the Court concludes that Rubik’s Pubes does not have standing to bring this appeal based on the language in the league constitution.  Because he does not have standing to bring the appeal, there is no need to address the second question presented in terms of whether the underlying trade should have been approved.  The decision to approve the trade stands.

IT IS SO ORDERED.

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